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Ireland: Updated guidance on outbound payments defensive measures

A key element in determining whether the measures apply is the association test. 

April 22, 2026

The Irish Revenue on March 30, 2026, published updated guidance on outbound payments defensive measures that:

  • Provides clarifications on the application of the association test, with a particular focus on Irish partnerships
  • Clarifies that partners holding 5% or less of the beneficial interest, with no management rights, are not treated as associated people
  • Expands the individual‑based association rule, confirming that entities may be treated as associated not only when an individual directly holds more than 50% of each entity, but also when such ownership or economic rights are held directly or indirectly through persons connected with that individual

Read an April 2026 report prepared by KPMG’s EU Tax Centre

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